Ditto Truff!!

Why don't I feel a sense of relief with this announcement?

Maybe they should read the diversity standards rule they just finalized. I guess it applies to everyone but them.

My biggest complaint in the entire TRID mess is this: the whole "idea" behind TRID is that the old way of doing things was confusing for the consumer, so we must clean it up so that these consumers can understand the disclosures. Does anyone on BOL think that a Loan Estimate is easier to understand than a Good Faith Estimate or early TIL or that a Closing Disclosure is easier to understand than a HUD-1 or TIL Disclosure Statement? Not saying they're harder necessarily either....just that people either are inclined to understand such a disclosure or they're not......i think our average customer would think not much has changed, if they care at all. So what greater purpose is getting served here? We all got to read 10 million words, 95% of customers still won't care nor understand their disclosures, and the sun will go down tonight as every night.

That's the truth.

I think they are harder to understand. The wording of a few sections is just not good at all and is going to be very confusing. We used to think the 'amount financed' was challenging...It pales compared to "closing costs financed".

Not to mention the TIP......


And the biggest effect will be to inconvenience consumers with all the waiting....

Actually, i agree with that. They are harder to understand. (So Congress, mission accomplished i guess.)

I still don't understand how they had roomfuls of test consumers who came to the conclusion that this was the way to go...somehow I feel they were overwhelmed and just nodded in agreement to everything!

the administrative error cited is the CFPB's neglect to issue a notice in line with the Congressional Review Act 60 days before the rule takes effect. They basically "forgot" and had to file for a 2 week delay. This 2 week delay requires a period of Notice an Comment - so they decided to go with a 2 month delay.

Nice error! Now I can take my vacations at the end of July just like I had planned

Can I ask for a two week or two month delay to fix an administrative error when they arrive to do their exam? I think not and I bet I can't use that for a response to an error either.

Why wasn't I content being a teller all those years ago? I think a teller's life has gotten a little easier and I am absolutely sure our compliance jobs have not.

Thanks for letting me vent.

[quote=Truffle Royale]I foresee the problem being the fact that management and employees alike will say 'well, don't have to worry about that now. Let's turn our attention to (inset a project.) That leaves me sounding like the little boy who cried wolf.

Exactly! I was just getting the lending staff to take me seriously. Now I will have to get them re engaged in September because lenders and processors only work in the "today world".

The lenders are so used to ignoring me, that of the four people I sent the "announcement" to, only one (and she's over mortgage servicing, the least relevant of the areas contacted) has even opened the email.

The relevant parties (the department heads and lending VP) go on thinking it's still 8/1.

I'd like to see this. I understand that there are MANY people who have not received updates from their software vendors. We are fortunate to have received the updates and been testing, testing, testing, and testing. I do feel we are ready as long as we get another update from our vendor to fix a couple of things.

I am on the fence. I like the extra time but also was ok with the 8/1 date as well.

:dodges rock throwing:

When I told our CAO about it she replied, "Well that's great, but for the love of God do NOT tell anybody else!"

Not a chance.

Any idea when the proposed amendment to delay the effective date will be approved/final?

After the comment period expires.

When does it expire?

The comment period hasn't even opened yet.

I've already had this happen! And we are one of the banks still waiting on system updates so no testing has been completed.

The underlying issue is that we have two regulations that apply different definitions and processes to the same loan.

What needs to happen is a new Act that amends TILA and RESPA to create a new regulation that covers all consumer credit secured by real estate and have uniform definitions as well as a triage of protection and disclosures that start with owner-occupied dwelling receiving the greatest amount of protection and moving on down to non-owner occupied dwelling (where the loan is for a consumer purpose) and then to non-residential real estate where the loan is for a consumer purpose.

Right now we have a byzantine flying spaghetti monster of different sections, notes, commentary, FAQ and guidances that wrap up lenders and borrowers in a sea of incomprehensible disclosures, most of which have little correlation to how the real estate industry actually does things.

Amen, sistah!
But you're thinking with a compliant, industry educated brain.
Wish the CFPB had some of those....

(lol at the 'byzantine flying spaghetti monster')

I'm sure in 5 years, a monstrous new regulation combining Reg. Z and RESPA will come down the pike and we'll be in this boat again, because "simplifying" regulations into something actually workable is not a strength of our Congress and the CFPB. So they'll hail it as a great, new, simplified thing that will be great for the industry; meanwhile, all of us will retire en masse.